In 2021, the GRA migrated fully to an online portal for the filing and payment of taxes. This was in fulfilment of the GRA's Digitization Agenda, i.e., to automate the end-to-end processes from tax filing to tax payments. Automating the processes was aimed at easing tax compliance and mitigating the incident of loss of information due to improper handling of documents, and disasters, among others.

One such process which has been automated as of 2023 is the obtainment of a TCC.

The TCC is an essential requirement for businesses and individuals seeking to undertake certain transactions, including the clearing of imported goods, registration of land titles, renewal of licenses by members of professional bodies, and bidding for government contracts. Due to the migration of the TCC procuration processes onto the portal, the GRA no longer processes manual TCC applications.

This move, the GRA asserts, will bring several benefits to the taxpayer; including instant access to the TCCs upon application, avoidance of fake TCCs, reduction in compliance costs, elimination of delays, as well as the ability to apply for a TCC at any time and as often as necessary.

Despite the enormous benefits this new system is set to bring, the online TCC process may present challenges. Checks at the GRA have revealed that the online portal is now being updated with historical tax records of taxpayers. Several taxpayers who have attempted to make use of this system have seen their applications being automatically rejected even though they may have fulfilled or fully complied with all their tax obligations at the time of application. Additionally, there are instances where some taxpayers who are not required to file certain tax returns find those returns showing as pending on their taxpayer portal and dating back several years.

Even though this issue is no fault of the taxpayer, in practice, the onus has been on the taxpayer to prove that the information displayed on the taxpayer's portal is inaccurate or otherwise. The attempt to have the issue resolved presents certain challenges:

• The GRA may require the taxpayer to provide information already provided to or in the GRA's possession (e.g., tax returns, proof of payment)
• The GRA's capacity to resolve this issue
• Several reconciliation meetings and time spent to do same

In view of these challenges, taxpayers should take the following key steps to ensure that their tax records are up to date:

• Login to your taxpayer portal and obtain your statement for the respective periods and the various tax types displaying pending liabilities.
• Use the statement to identify gaps in your tax compliance position. These gaps may come in the form of payments made but not reflected on the taxpayer portal, liabilities that are erroneously assessed (sometimes due to the filing of wrong tax returns) by the GRA, outstanding interests due to the automatic calculation of late payment interest on the GRA portal and pending returns that may not apply or are already filed.
• Provide the GRA with documentation including payment receipts, filed returns, etc. to fill the gaps. In cases of pending returns that are not applicable, disclose same to the GRA and explain to them why those returns do not apply.

Once the above steps are completed and all issues are fully resolved, not only does the taxpayer avail itself of the benefits presented by this new system as mentioned above but also:

• Avoids arbitrary assessments from the GRA
• Saves time during tax audits due to having all records in order

EY has the experience to assist taxpayers in reconciling their records on the taxpayer's portal to be compliant and to benefit fully from the new system.

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For additional information with respect to this Alert, please contact the following:

Ernst & Young Chartered Accountants, Accra

• Isaac N. Sarpong (isaac.sarpong@gh.ey.com)

Ernst & Young Société d'Avocats, Pan African Tax – Transfer Pricing Desk, Paris

• Bruno Messerschmitt (bruno.messerschmitt@ey-avocats.com)

Ernst & Young LLP (United Kingdom), Pan African Tax Desk, London

• Kwasi Owiredu (kwasi.owiredu@uk.ey.com)

Ernst & Young LLP (United States), Pan African Tax Desk, New York

• Brigitte Keirby-Smith (brigitte.f.keirby-smith1@ey.com)
• Dele A. Olagun-Samuel (dele.olaogun@ey.com)